The Queen v. Timagami Financial Services Ltd., 82 DTC 6268, [1982] CTC 314 (FCA) -- summary under Cumulative Eligible Capital

Where the consideration for sale of goodwill is to be paid to the vendor over a series of years, then 1/2 of the amounts so paid are included as eligible capital amounts in computing the vendor's income in the years of payment as opposed to the earlier year of sale: in the year of sale, the amounts to be paid in subsequent years were not then "payable".